Justia Constitutional Law Opinion Summaries

Defendant, his brother, his sister-in-law, and his cousin worked together in a tiling business in Oklahoma. All four individuals were hired to install tile in a fast-food restaurant under construction in Clinton. While working on the job, Defendant stabbed and killed the general manager with no apparent provocation or motive. The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant’s motion to suppress statements Defendant made to the police; (2) the joinder of the firearms charges with the murder charge for trial did not prejudice Defendant; (3) the admission of certain hearsay evidence at trial did not prejudice Defendant; (4) the trial court did not err in denying Defendant’s first motion for a new trial without an evidentiary hearing; and (5) trial counsel was not ineffective for failing to pursue a defense of lack of criminal responsibility based on evidence that Defendant may have been suffering from a spontaneous recurrence of methamphetamine-induced psychosis at the time of the stabbing. View "Commonwealth v. Spray" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on a theory of deliberate premeditation and of unlawful possession of a firearm. The Supreme Judicial Court affirmed the order denying Defendant’s motion to suppress identification evidence and affirmed Defendant’s convictions, holding that the trial judge did not err in (1) denying Defendant’s motion to suppress, as the police had good reason to conduct a showup identification procedure, and Defendant did not meet his burden of showing that he was subjected to a showup identification procedure that was unnecessarily suggestive; (2) admitting into evidence surveillance videotape recordings; (3) limiting cross-examination of a witness on the issue of bias; (4) deciding not to discharge a juror; and (5) instructing the jury. View "Commonwealth v. Meas" on Justia Law

After a jury trial, Defendant was convicted of two counts of murder in the first degree. The Supreme Judicial Court affirmed the convictions, holding that the trial judge (1) did not err in denying Defendant’s motion to suppress his statements to police; (2) did not deny Defendant’s Sixth Amendment right to a fair trial by denying Defendant’s motion for a change of venue; (3) did not err in denying the admission of certain “third-party culprit” evidence and Defendant’s request for a third-party culprit instruction at trial; and (4) did not abuse his discretion in excluding expert testimony regarding the phenomenon of false confessions. View "Commonwealth v. Hoose" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theory of felony-murder, with armed robbery as the predicate felony. The Supreme Judicial Court affirmed the conviction of murder in the first degree, holding (1) any error by the superior court in denying Defendant’s motions to suppress statements made to police as well as certain physical evidence gathered as a result of those statements was harmless; (2) the trial judge properly precluded Defendant from cross-examining a key Commonwealth witness as to prior false accusations she had made; (3) the evidence was sufficient to support Defendant’s conviction of armed robbery, the predicate offense for his conviction of murder in the first degree; and (4) the trial judge did not err in denying Defendant’s motion for a new trial on the ground of ineffective assistance of counsel. View "Commonwealth v. Martin" on Justia Law

After Defendant was indicted on murder charges, Defendant filed a motion to suppress evidence of cell site location information (CSLI) associated with the cellular phone he was using because the CSLI was obtained without a valid search warrant based on probable cause. The superior court granted the motion to suppress, concluding that Defendant’s rights under article 14 of the Massachusetts Declaration of Rights were violated because, although the Commonwealth had obtained the CSLI from Defendant’s cellular servicer provider pursuant to a valid court order under the Federal Stored Communications Act (SCA), the Commonwealth’s access to the CSLI constituted a search within the meaning of article 14. The Supreme Court agreed with the motion judge, holding that although the CSLI in this case was a business record of Defendant’s cellular servicer provider, Defendant had a reasonable expectation of privacy in it, and, under the circumstances, the warrant requirement of article 14 applied. Remanded to allow the Commonwealth to present evidence that the affidavit in support of its application for an order under the SCA demonstrated probable cause for the CSLI records. View "Commonwealth v. Augustine " on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theories of deliberate premeditation, extreme atrocity or cruelty, and felony-murder. The Supreme Court affirmed Defendant’s convictions, holding, inter alia, that (1) the motion judge did not err in denying Defendant’s motion to suppress his interview at a house of correction or Defendant’s motion to suppress the fruits of a search of his girlfriend’s home; (2) it was error to allow the Commonwealth’s fingerprint expert to make certain statements during her testimony, but the error did not create a substantial likelihood of a miscarriage of justice; (3) the absence of an instruction to the jury that they must unanimously agree on the predicate felony caused no prejudice to Defendant; and (4) the judge did not err in instructing the jury that the crimes of armed robbery and home invasion are “inherently dangerous to human life.” View "Commonwealth v. Wadlington" on Justia Law

After a jury trial, Defendant was convicted of armed robbery. Defendant appealed from his conviction and from the revocation of his probation that resulted from the conviction, challenging the sufficiency of the evidence identifying him as the perpetrator. The Supreme Court affirmed the conviction and concluded that there was no error in the revocation of Defendant’s probation, holding (1) the evidence was sufficient to support Defendant’s conviction; (2) the prosecutor did not misstate the evidence in her closing argument; and (3) the judge who presided at Defendant’s probation revocation hearing did not violate Defendant’s due process rights by denying Defendant’s requests to present additional evidence as to whether he committed the robbery. View "Commonwealth v. Joyner" on Justia Law

After a jury trial, Defendant was found guilty of deliberately premeditated murder in the first degree and sentenced to life imprisonment without the possibility of parole. Defendant was sixteen years old at the time of the murder. Defendant appealed, raising several allegations of error. The Supreme Court (1) affirmed Defendant’s convictions, holding that the motion judges and trial judge did not commit reversible error or abuse their discretion in their rulings and that Defendant’s counsel did not provide ineffective assistance; but (2) remanded the case to the superior court for resentencing, holding that, pursuant to the Court’s decision in Diatchenko v. Dist. Attorney interpreting the U.S. Supreme Court’s decision in Miller v. Alabama, Defendant was eligible for parole in accordance with the terms of Mass. Gen. Laws ch. 127, 133A. View "Commonwealth v. Ray" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree. During jury empanelment, the court room was closed to all members of the public, including Defendant’s family. After the Supreme Court’s ruling in Commonwealth v. Cohen, which held that the right to a public trial extended to jury empanelment, Defendant filed a motion for a new trial, asserting that the closure of the court room during his trial was structural error requiring reversal. The motion judge denied the motion, concluding that the seventy-nine minute closure was de minimis. The Supreme Court affirmed on other grounds, holding (1) the closure of a court room for the entire empanelment process is not de minimis, but Defendant waived his right to a public trial where his counsel was aware of the closure and did not object; and (2) counsel’s failure to object did not constitute ineffective assistance of counsel. View "Commonwealth v. Morganti" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on theories of deliberate premeditation and felony-murder. The Supreme Court affirmed Defendant’s convictions, holding (1) the motion judge correctly denied Defendant’s motions for a new trial based on Defendant’s assertions that newly discovered evidence called into question the trial testimony of two of the Commonwealth’s witnesses, and the motion judge did not abuse her discretion in denying Defendant’s requests for posttrial discovery; and (2) the trial judge did not commit prejudicial error in failing to give a specific instruction on witness credibility and in making certain evidentiary rulings. View "Commonwealth v. McGee" on Justia Law